351. Special Damages Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 [Name of plaintiff] [also] claims damages for [identify special damages]. To recover for this harm, [name of plaintiff] must prove that when the parties made the contract, [name of defendant] knew or reasonably should have known of the special circumstances leading to the harm. ___________________________________________________________________________ New September 2003